Effective date: December 1, 2022

She Plays™ Privacy Policy

1. SCOPE OF PRIVACY POLICY

She Plays™ (also referred herein as “we”, “us”, or “our”) is committed to protecting your privacy (as the “End User” or “you”) in conjunction with the use of the She Plays’s website located at https://she-plays.com/, store.she-plays.com and the She Plays application (collectively, the “Site”) and the provision of free online fantasy sports games for any End User over the age of 13, and certain subscription-level content you may have access to through the Site (together with the Site, the “Services”).  This privacy policy describes, among other things, the types of information collected about you when you visit our Site or use our Services, how your information may be used and disclosed, how you can control the use of your information, and how your information is protected.  It shall be interpreted in conjunction with our Terms of Service.

By using our Site or Services, you consent to the worldwide, perpetual collection, transfer, manipulation, storage, disclosure and other use of your information as described in this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Site or Services.

Please note that any content you put on our webpage is considered personally identifiable information pursuant to our policy and may be republished by us.

She Plays employs physical, electronic, and managerial control procedures to safeguard and help prevent unauthorized access to your information. We choose these safeguards based on the sensitivity of the information that we collect, process and store and the current state of technology. Our outsourced service providers who support our operations are also vetted to ensure that they too have the appropriate organizational and technical measures in place to protect your information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted to the Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. In the event that there is breach in the information that we hold; we shall notify of such breach via email or via notice on the Services.

Here is short summary of data the categories of data we have collected, disclosed, and sold over the last twelve months. The rest of this Privacy Policy provides more in-depth information on our privacy practices.

  • Identifiers, such as contact details, such as real name, alias, address, telephone number, unique personal identifiers, online identifiers, IP address, email address, and account name.
    • Do we collect? Yes
    • Will we disclose this data as part of our business? Yes
    • Will we sell this data? No
  • Categories of PI described in the California Consumer Privacy Act, GDPR or otherwise (including name, email, phone number, mailing address, birthday, SSN, driver’s license number, bank account number, health information) 
    • Do we collect? Yes
    • Will we disclose this data as part of our business? Yes
    • Will we sell this data? No
  • Commercial information: (Transaction information, purchase history, financial details, and payment information)
    • Do we collect? No
    • Will we disclose this data as part of our business? No
    • Will we sell this data? No
  • Geolocation data: (device location)
    • Do we collect? Yes
    • Will we disclose this data as part of our business? Yes
    • Will we sell this data? Yes
  • Internet or other electronic network activity information: (Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements)
    • Do we collect? Yes
    • Will we disclose this data as part of our business? Yes
    • Will we sell this data? Yes
  • Inferences drawn from other personal information to create a profile about a consumer: (for example, an individual’s preferences and characteristics)
    • Do we collect? No
    • Will we disclose this data as part of our business? No
    • Will we sell this data? Yes
  • Biometric information
    • Do we collect? No
  • Characteristics of protected classifications under California or United States federal law
    • Do we collect? Yes
  • Audio, visual or similar information
    • Do we collect? Yes
  • Professional or employment related information
    • Do we collect? No
  • Non-public education information (per the Family Educational Rights and Privacy Act)
    • Do we collect? No

2. INFORMATION COLLECTED BY US AND ITS USE 

You are not generally required to provide information about yourself when you visit our Site.  However, should you wish to register for certain Services, access certain content, or directly contact us from the Site, you may be asked for some or more of the following information:

  • Contact information, such as your name, email address, postal address, zip code, phone number, and other related information
  • User name, password, and password hint questions
  • Location/domicile
  • Age and date of birth
  • Profile photograph (optional)
  • Other demographic information such as gender and job information
  • Information for maintaining a public profile
  • Preferred means of communication
  • Information related to any other correspondence you send to us

In addition, should you wish to use certain of our services, you may be asked to provide the following:

  • Payment verification information, such as credit card number or PayPal account number and the email address linked to your PayPal account
  • Social security number or comparable national identifier
  • Other information as related to processing your payment and confirming your payment information, age and location

Finally, should you win any of our contests, you may be asked to provide the following:

  • Relevant information about yourself needed to assist us in marketing future contests
  • Information required to provide the proper tax forms related to your winnings

Non-personal data includes any data that cannot be used on its own to identify, trace, or identify a person. We may collect your device information, including GPS data and IP address. When non-personal data you give to us is combined with personal data we collect about you, it will be treated as personal data and we will only use it in accordance with this Privacy Policy.

How we collect information

We collect information when you provide it do us directly through an interaction with us; for example

  • When you apply or register for the service;
  • When you fill out a survey or contact us form;
  • When you contact us through our Site;
  • When you contact us for Service requests.

Why we collect and how we use your information.  (Legal Basis)

We collect and use your personal data when we have a legitimate purpose to do so, including the following reasons:

  • to verify your eligibility to use the Services;
  • when it is necessary for the general functioning of the Services, including to contact you;
  • when it is necessary in connection with any contract you have entered into with us or to take steps prior to entering into a contract with us;
  • when we have obtained your or a third party’s prior consent;
  • when we have a legitimate interest in processing your information for the purpose of providing or improving our Services;
  • when we have a legitimate interest in using the information for the purpose of contacting you, subject to compliance with applicable law; or
  • when we have a legitimate interest in using the information for the purpose of detecting, and protecting against, breaches of our policies and applicable laws.

We may use aggregated (anonymized) information about our End Users, and information that does not identify any individual, without restriction.

3. INFORMATION COLLECTED IN CONJUNCTION WITH THIRD PARTIES

The following information may be collected automatically from all visitors to the website by either us or third parties acting on our behalf and may be used for internal customer tracking and business purposes, as well as any other purposes to support our business and comply with matters of law:

  • Your browser type and operating system
  • Your Internet Protocol (“IP”) address
  • Sites you visited before and after visiting our Site
  • Web pages and advertisements you view and links you click on from our Site
  • Other unique identifiers, including mobile device identification numbers that can identify the physical location of your device in accordance with applicable law
  • Information collected through cookies, web beacons and other technologies
  • Standard server log information
  • Other information collected naturally by Google Analytics, AWS, and similar programs

Your data may be processed, collected, shared or stored by third-party vendors, including our third-party payment processors or other service providers we use to conduct business. Such processing, collection, sharing or storing of data by such third parties is not processed, collected, shared or stored by us. We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. This length of time may vary according to the nature of your relationship with us. Personal data will be purged after five (5) years of nonuse of an Account.

Information from our service providers: We may receive information about you from third-party service providers that we engage for marketing our products and Services.

Information from social media sites and other publicly available sources: When you choose to login or sync your account through a third-party account, or interact or engage with us on social media sites, or other social platforms, through posts, comments, questions, instant messaging, and other interactions, we may collect such publicly accessible information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. Once collected, this information may remain with us even if you delete it from the social media sites. We may also add and update information about you, from other publicly available sources.

4. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We only use payment and identity verification information (such as credit card numbers, driver’s license numbers and social security numbers, or comparable national identifiers as necessary): for completing particular transactions; if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to protect the intellectual property rights of others; to address fraud, security or technical issues; or to protect our rights or property.

All other information collected about you may be used for a wide range of other purposes, including to fulfill requests for services, to enable you to participate in contests and polls, to analyze the demographics of our customer base, to customize content and advertising to your needs, to market our brand, contests and winners, to share with actual and potential sponsors for joint marketing purposes, to share with, or sell to, third parties to the extent permitted by law, to prevent potentially prohibited or illegal use of our site and services or use of our site and services in a manner that would violate the Terms of Service, and for any other purpose disclosed to you, or reasonably known by you, at the time we collect the information.

5. ACCESSING, CONTROLLING, CHANGING AND REMOVING INFORMATION

If you would like to prevent us from collecting your information completely, you should cease use of our Services. You can also control certain data via these other methods:

Correction capabilities: You have the ability access and correct any inaccuracies in your personally identifiable information by contacting us at contact@she-plays.com.

Opt-out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages or by contacting us directly at contact@she-plays.com. However, you will continue to receive notices and essential transactional emails.

Optional information: You can always choose not to fill in non-mandatory fields when you submit any form or information linked to our Services.

If you choose to share information with us, you may have the opportunity to update that information on our website or by contacting us at the following address: contact@she-plays.com. If you ask us to shut down your Account or delete your information, we will disable your Account within a reasonable period of time.  Please note, however, that we may retain certain information about you to satisfy both our legal and security obligations.  For example, some of your information may remain in backup storage even if you ask for it to be deleted. In some cases you may be entitled under local laws to access or object to the processing of information that we hold relating to you.

We acknowledge your right to request access, amendment, or deletion of your data. We also recognize that you have the right to prohibit sale of your data.

You can exercise the rights described above, by sending an email to contact@she-plays.com. Only you, or an agent authorized to make a request on your behalf, may make a request related to your personal information.

We cannot respond to your request if, (i) we cannot verify your identity; or (ii) your request lacks sufficient details to help us handle the request. We will make best efforts to respond to your request withing forty five (45) days of its receipt. If we cannot respond in forty five (45) days, we will inform you, in writing, the reason for the delay and will respond to your request within 90 days. Any information we provide will only cover the twelve (12)-month period preceding the request’s receipt.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We are not obligated to provide responses to your data requests more than twice in a twelve (12)-month period.

6. PASSWORD PROTECTION

We are committed to protecting your information.  All password protected sections of the website are encrypted with standard security measures. All user profiles and payment screens are password protected.

7.  CALIFORNIA USERS

Under the United States California Consumer Privacy Act, the Virginia Consumer Data Protection Act, Nevada’s privacy laws regarding notice of information collected, and various other states located in the United States, residents of these states have certain statutory data rights. We provide the same control and rights over your data no matter where you choose to live in the United States. As a user of our Services, you have the following control over your data:

  • Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared.
  • Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
  • Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
  • Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
  • Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing

For any such request under this Section 7, please contact us at the following address:  contact@she-plays.com. For all requests, you must put the statement “Your Privacy Rights” in the body of the request, as well as include your name, street address, city, state and zip code.  Please note that we will not accept requests via the telephone, mail or facsimile, and we are not responsible for notices that are not labeled or otherwise improperly sent, or which have other incorrect information.

8.  USERS IN THE EUROPEAN ECONOMIC AREA

If you are a resident of the European Economic Area (“EEA”), or are accessing this site from within the EEA, you may have certain rights under the European Union’s General Data Protection Regulation (GDPR). The information collected from you by us must be explained as follows in order for GDPR compliance.  To make any of these requests, please contact contact@she-plays.com.

  • She Plays’ legal basis for the processing your data includes the necessity to contract with you and perform our Services.
  • She Plays’ legitimate interests in collecting such data include legitimate interests of our business, including but not limited to performing Services for you and other End Users, collecting necessary information in order to safely and accurately perform such Services, fraud prevention, information security, direct marketing, and legal compliance.
  • She Plays does not collect categories of personal data from sources other than yourself.
  • She Plays may transfer personal data outside of the jurisdiction through its use of Amazon Web Services (AWS)  
  • She Plays stores this information for as long as necessary to conduct Services. We will delete any data that has not been used for a period of five (5) years or longer.
  • She Plays does not use automated decision-making, such as profiling, during your application process.
  • If you are a citizen where which GDPR applies, you have the right to object to or restrict data processing, the right to erasure also known as the right to be forgotten, and the right to data portability.
  • At any time, you have the right to withdraw your consent for us to use, store, or collect your data and file a complaint with your local supervisory authority.

9. INTERNATIONAL USERS

Our website is hosted in the United States and is intended for and directed to users in the United States.  If you are a user accessing the website from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from the laws of the United States, please be advised that through your continued use of our website, you consent to jurisdiction in the United States and exclusively United States choice of law pursuant to our Terms of Service.  Further, pursuant to U.S. law, this notice and our Terms of Service, you are hereby transferring your personal information to the United States and you consent to that transfer. 

10.  OUR POLICY TOWARD MINORS

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or through any of its features, register or sign up for Services on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at contact@she-plays.com.

Residents of some states under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

11.  USER GENERATED CONTENT

Certain aspects of our site may enable users to submit their own User Content (as defined in our Terms of Service) for contests, blogs, message boards and other function.  Publication of any such User Content is subject to our Terms of Service.  Please remember that any information you disclose, as well as any video and audio images you provide, becomes public information and thus you should exercise caution when considering what information to disclose in this manner.  We cannot necessarily prevent such information from being used in a manner that may violate this Privacy Policy, the law or your personal privacy and safety.

12.  ADDITIONAL INFORMATION ON THIRD PARTY SITES

When you select a link to a third party website (for example, if you link to PayPal in order to pay for a service or product), you will be leaving our site.  Any information that you disclose to a third party site will be governed by that site’s privacy policy. 

We may, for our legitimate interests, share certain information with contractors, service providers, third party authenticators, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. Some of the functions that our service providers provide are as follows:

  • Host server infrastructure and storage;
  • Business analytics services;
  • User and identity verification management;
  • Payment processing;
  • Site log analytics service for activity, performance, and troubleshooting;
  • Marketing, sales, and service management;
  • Conducting our Services; and
  • Email management services.

We may use and disclose your personal data that you have voluntarily provided to us, including your health information, to third parties who contract with us to conduct our Services. We hereby acknowledge that any such disclosure shall be in compliance with all applicable data privacy laws in any given disclosure and further acknowledge compliance with any such policies of covered third party entities we may work with.

13.  MERGER, ACQUISITION SALE OR BANKRUPTCY

We may, for our legitimate interests, share your information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Data about our End Users is among the assets transferred. You will be notified of any such change by a prominent notice displayed on our Services or by e-mail. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer.

14. LAW ENFORCEMENT AND OTHER GOVERNMENTAL AGENCIES

We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. This may involve the sharing of your information with law enforcement, government agencies, courts, and other organizations.

15.  CHANGES TO THIS POLICY

We may change this Privacy Policy pursuant to the procedures outlined in our Terms of Service. Unless otherwise noted, our current Privacy Policy applies to all information that we have about you and your account. If we make changes to this Privacy Policy we will notify you by publication here. By continuing to access or use the Service after such changes take effect, you agree to be bound by the revised Privacy Policy.

16. QUESTIONS ABOUT THIS POLICY

If you have any questions regarding this Privacy Policy please contact us at
contact@she-plays.com and we will make an effort to respond within a reasonable
time period. 

Last Updated: December 1, 2022